e · attachment 2 - vsmp ms4 general permit 2015 annual report jbm-hh minimum control measure...

Attachment 1 - VSMP MS4 General Permit 2015 Annual Report

JBM-HH Minimum Control Measure Progress Evaluation

JBM-HH MS4 2015 Annual Report - Attachment 1 Page 1 of 3



Permit Section: Requirement Implementation Summary

Minimum Control Measure 1: Public Education and Outreach on Stormwater Impacts

Section II.B.1.g(1) : A list of the education and outreach activities conducted during the reporting period for each high-priority water quality issue, the estimated number of people reached, and an estimated percentage of the target audience or audiences that will be reached.

High-Priority WQ Issue

Activity Target Audience/Estimated Total Audience

Estimated % Reached

Oil & grease, hydrocarbons and related pollutants

Revised and redistrubuted Stormwater Pollution Prevention brochures to soldiers

Published one article in the Pentagram, JBM-HH’s weekly newspaper

Developed and delivered stormwater pollution prevention presentation and activity to CDC preschoolers

Updated web page with new information

Civilian Employees/1,730 Active Duty Military Population/~8,300 Residents/~1,000 CDC preschoolers/~60

20% 20% 30% 75%

Sediment

Published one Pentagram article

Provided additional employee training (DPW staff)

Prepared list of construction site inspection requirements for construction project managers

Civilian Employees/1,730 DPW Construction Project Managers and DPW maintenance employees/~100

35% 80%

Trash and Litter

Published one Pentagram article regarding proper trash disposal and impact of litter

Created Stormwater Pollution Prevention presentation distributed to new civilian employees and active duty military

Civilian Employees/1,730 Active Duty Military Population/~8,300 Residents/~1,000

35% 20% 40%

Section II.B.1.g(2): A list of the education and outreach activities that will be conducted during the next reporting period for each high-priority water quality issue, the estimated number of people that will be reached, and an estimated percentage of the target audience or audiences that will be reached.

Education and Outreach activities planned for the next reporting and the estimated target audiences to be reached are summarized below:

High-Priority WQ Issue

Activity Target Audience/Estimated Total Audience

Estimated % to be Reached

Oil & grease, hydrocarbons and related pollutants

Publish one article in the Pentagram

Post information on JBM-HH Facebook page regarding spill reporting and car washing

Update web page with new information


20% 20% 30%

Sediment

Develop and publish basewide stormwater policy


Civilian Employees/1,730 DPW Construction Project Managers and DPW maintenance employees/~100

35% 80%

Trash and Litter

Publish one Pentagram article regarding proper trash disposal and impact of litter

Mark storm drains in high-traffic areas

Continue presenting Stormwater Pollution Prevention in-briefing slides to new civilian employees and active duty military



35% 20% 40%

Minimum Control Measure 2: Public Involvement/Participation

Section II.B.2.d(1): A web link to the MS4 Program Plan and annual report http://www.jbmhh.army.mil/WEB/JBMHH/Directorates/EnvironmentalManagement.html

http://www.jbmhh.army.mil/WEB/JBMHH/Directorates/EnvironmentalManagement.html







Section II.B.2.d(2): Documentation of compliance with the public participation requirements of this section.

The updated MS4 Program Plan has been posted on the JBM-HH website. The Annual Report will be posted within 30 days of submission to DEQ. A stormwater pollution prevention presentation was delivered to 40 preschool students at the JBM-HH child daycare center. Earth Day, base-wide cleanup, and paper shredding and recycling activities were held that involved multiple organizations on the Installation. EMD is currently in the process of planning public involvement activities for the next year as described in the MS4 Program Plan.

Minimum Control Measure 3: Illicit Discharge Detection and Elimination

Section II.B.3.f(1): A list of any written notifications of physical interconnection given by the operator to other MS4s.

There have been no written notifications of interconnections issued. A site visit was conducted by Arlington County in June 2014 to review JBM-HH outfall locations and discharge area characteristics.

Section II.B.3.f(2): The total number of outfalls screened during the reporting period, the screening results, and detail of any follow-up actions necessitated by the screening results.

All 24 outfalls were screened during 2014. As of September 2015, approximately 75% of the Installation’s outfalls have been inspected. Conditions requiring follow-up actions were observed at three outfalls; work orders have been submitted to maintain the outfalls and repair age-related damage.

Section II.B.3.f(3): A summary of each investigation conducted by the operator of any suspected illicit discharge. The summary must include: (i) the date that the suspected discharge was observed, reported, or both; (ii) how the investigation was resolved, including any follow-up, and (iii) resolution of the investigation and the date the investigation was closed.

Illicit discharges related to vehicle washing were observed on 27-28 Aug 14 at the Fire Department and 12 May 2015 at The Old Guard Motor Pool. At both locations, discharges of non-sudsy water were observed. Memos detailing the observations, the effects of vehicle washing on water quality, and corrective actions were issued, and no subsequent instances of vehicle washing or rinsing were observed in follow-up inspections on 14 Oct 14 at the Fire Department and 25 June 15 at The Old Guard Motor Pool, and the investigations were closed. To curb future illicit discharges related to vehicle washing, a base-wide stormwater policy was developed in August 2015 to address vehicle washing, spills and leaks, best management practices, and reporting. There are also plans to bring an additional commercial car wash and water recycling system online for use by JBM-HH vehicles.

Minimum Control Measure 4: Construction site stormwater runoff control

Section II.B.4.f(1): Total number of regulated land-disturbing activities Land disturbing activities during this reporting year included demolition of a barracks and replacement of an underground water line.

Section II.B.4.f(2): Total number of acres disturbed Less than 5 acres.

Section II.B.4.f(3): Total number of inspections conducted Thirty-five (35) inspections of construction sites were conducted at JBM-HH during the last permit year.

Section II.B.4.f(4): A summary of the enforcement actions taken, including the total number and type of enforcement actions taken during the reporting period.

As a result of observed noncompliance with controls outlined in their Erosion and Sediment Control Plan during three inspections in March-April 2015, the US Army Corps of Engineers Administrative Contracting Officer issued a warning letter on 4/14/15. Deficiencies were corrected by the next inspection on 4/17/15.

Minimum Control Measure 5: Post-construction stormwater management in new development and development on prior developed lands Section II.B.5.e(9): the operator shall annually track and report the total number of inspections completed and, when applicable, the number of enforcement actions taken to ensure long-term maintenance. The operator shall submit an electronic database or spreadsheet of all stormwater management facilities brought online during each reporting year with the appropriate annual report.

JBM-HH is a military installation. Inspection and maintenance of all stormwater management facilities on the Installation is the responsibility of the Directorate of Public Works (DPW). The United States Army Environmental Command performed 15 inspections. Maintenance issues are managed through the DPW work order process; enforcement actions are not applicable.

There were no new stormwater management facilities brought online during this reporting period.

Minimum Control Measure 6: Pollution prevention/good housekeeping for municipal operations Section II.B.5.g(1) A summary report on the development and implementation of the daily operational procedures

Daily operational procedures for DPW employees were completed by the 30 June 2015 deadline and were disseminated among the affected DPW departments.

Section II.B.5.g(2) A summary report on the development and implementation of the required SWPPPs

A JBM-HH SWPPP that addresses all municipal operations for the Installation was prepared to comply with the Installation’s VPDES Industrial Stormwater Permit. This SWPPP has been implemented since 2009 and was updated in June 2015.

Section II.B.5.g(3) A summary report on the development and implementation of the turf and landscape nutrient management plans that includes: (a) The total acreage of lands where turf and landscape nutrient management plans are required; and (b) The acreage of lands upon which turf and landscape nutrient management plans have been implemented

Turf and landscaped areas at the Installation are generally limited to small maintained yards and landscaped areas surrounding residences and buildings. The only large area that may have nutrient applications is the Summerall Field. This area is approximately 9 acres and is used for ceremonies, parades, and other similar activities. The coordinates for this area are: N38.881746, E-77.081838. The need for a nutrient management plan will be evaluated, and if a plan is required, it will be developed in accordance with the permit conditions.







Section II.B.5.g(4): A summary report on the required training, including a list of training events, the training date, the number of employees attending training and the objective of the training.

Annual stormwater pollution prevention and spill prevention training is provided for civilian employees and active-duty military personnel whose duties involve industrial and maintenance activities. The training addresses good housekeeping and pollution prevention. This training is deployed in a computer-based training format; after employees/personnel successfully pass an integrated test, a certificate of completion is generated. Since the training is computer based, training dates vary. During the last reporting period, 19 employees and active duty military personnel assigned to motor pool maintenance and DPW maintenance activities completed the training. An additional training module was developed in June 2015 to specifically address illicit discharge detection and elimination; this training was distributed to the same 19 employees on 6/17/15.


JBM-HH Minimum Control Measure Progress Report


BMP Schedule Measurable Goals Progress

Minimum Control Measure 1: Public Education and Outreach on Stormwater Impacts

1.1 - Provide information at Environmental Quality Control Committee (EQCC) meetings about water quality and pollution prevention.

Meetings are held quarterly. Meetings held quarterly; standing agenda item added to discuss water quality and pollution prevention issues

EQCC meetings held throughout permit year 2014-2015. Relevant discussion topics include stormwater nomcompliance observations and completed corrective actions from routine inspections, the Chesapeake Bay TMDL, designs of future stormwater best management practices to meet target reductions in the MS4 permit, and a summary of the new base-wide stormwater policy.

1.2 – Publish articles or advertisements in the Pentagram, a weekly publication with a circulation of over 19,000 in the national capital area military community, about seasonal practices to prevent stormwater pollution. Potential topics include fertilizer application (spring), pet cleanup practices (summer), leaf mulching and removal (fall), and use of deicing materials (winter).

Publish articles quarterly. Articles published quarterly. Articles have been published in the Pentagram about fall stormwater pollution prevention; bioretention areas, the effects of polluted stormwater runoff on water quality, and microplastics. Two of these articles were submitted to the Assistant Secretary of the Army, and one was also submitted to the quarterly Department of Defense Chesapeake Bay Journal.

1.3 – Establish an environmental information page on the JBM-HH Website. An environmental page can be established that provides tips on pollution prevention, household hazardous waste disposal, recycling opportunities, community environmental events, reporting illegal dumping, etc.

Update webpage annually. Webpage updated annually. JBM-HH website updated to include stormwater pollution prevention information and downloadable environment incident report form.

1.4 – Prepare public education brochures for activities with the potential to contribute to stormwater pollution and a general stormwater pollution awareness brochure for new residents and workers.

Update 2012 brochures and redistribute to appropriate residents and employees.

Brochures distributed to all target agencies/audiences.

Brochures were updated in 2015 and redistributed.

Minimum Control Measure 2: Public Involvement/Participation

2.1 – Participate in four base activities to promote stormwater pollution prevention and support local clean-up projects and groups or other opportunities for public involvement.

Activities scheduled periodically each year.

Number of activities held. JBM-HH partnered with Shred Ace, a company specializing in on-site document destruction, on several installation-wide document destruction events and supported Earth Day and base-wide cleanup events in April 2015. A stormwater pollution prevention presentation distributed to new civilian employees and active duty military during regular newcomer orientations to promote stormwater pollution prevention by employees and new residents. A stormwater pollution presentation and hands-on activity was developed and delivered to preschoolers at the JBM-HH child daycare center. During a tabling event, stormwater education brochures were distributed to soldiers.





Minimum Control Measure 3: Illicit Discharge Detection and Elimination

3.1 – Update GIS system with new storm drain system information as changes occur.

GIS data will be updated as needed based on construction activity.

New construction modifications added to GIS data.

An installation-wide as-built storm sewer survey was completed by DPW. Survey updates with storm system as-built information are provided periodically to DEM; GIS data was updated with new information in March 2015.

3.2 – Conduct dry weather inspections of all base outfalls to look for evidence of illicit discharges.

Inspections are conducted annually.

Inspections performed annually.

Inspections conducted of all outfalls; completed in July 2014. Outfalls will be re-inspected annually during permit years 2013-2018.

3.3 – Maintain database to track changes to building drains.

GIS data will be updated as building drains are located and site changes are made.

Database updated regularly. GIS data is being updated with storm drain survey data as it is obtained.

3.4 – Identify and eliminate illicit connections to storm drain. Ongoing sanitary sewer system upgrades are addressing cross connections as they are identified.

To be identified during DPW projects, as applicable, and during stormwater program inspections.

Inspections performed by Installation staff.

DPW projects and stormwater program inspections performed in 2014-15 did not identify cross-connections.

3.5 – Inform the JBM-HH community about hazards to human health and the environment from improper waste disposal and illegal dumping/ discharges. Information will be distributed through the sources identified in Minimum Control Measure (MCM) 1.

As identified in MCM 1. Information distributed at EQCC meetings, through Website, and in Pentagram articles.

Proper disposal of HazWaste and other materials is discussed at EQCC meetings and included in public education efforts. Base-wide cleanup held during April.

Minimum Control Measure 4: Construction Site Stormwater Runoff Control

4.1 – Review of all construction projects to insure that stormwater permit coverage and erosion and sediment control plan approvals have been obtained and that an adequate SWPPP has been prepared.

Review projects as they are scheduled.

Number of project reviews completed.

EMD continues to review new construction projects for compliance with regulatory requirements for issuance of stormwater permits and erosion and sediment control plan approvals. EMD reviews contractor-generated SWPPPs and uses them for the basis of regular construction inspections.

4.2 – Submit erosion and sediment control (E&SC) and stormwater management (SWM) plans to Virginia Department of Environmental Quality.

Plans are submitted to VA DEQ for review as projects are scheduled.

All construction plans for regulated land-disturbing activities (> 10,000 square feet of disturbance) submitted to VA DEQ.

The construction projects initiated during permit year 2014-15 obtained E&SC and SWM approvals from VA DEQ and Construction General Permit coverage, as appropriate.

4.3 – Maintain tracking system for construction projects; add field for number of acres disturbed.

Update tracking system annually.

Data available for annual updates.

Tracking system was updated for construction projects taking place in permit year 2014-15.

4.4 – Perform biweekly inspections of active construction projects’ E&S and SWM controls and pollution prevention BMPs; if deficiencies are identified, a copy of inspection report should be provided to construction operator with direction to address deficiencies.

Bi-weekly inspections for active construction projects.

Completed inspection reports for active construction projects.

Completed inspection reports maintained for construction projects at JBM-HH. A total of 35 inspections were performed on constructions sites during the last permit year.





Minimum Control Measure 5: Post-Construction Stormwater Management in New Development and Redevelopment

5.1 – Require post-construction BMPs that comply with VA DEQ SWM requirements. Develop agreement with USACE that construction projects under their oversight will comply with VA DEQ SWM requirements.

Plans are submitted to VA DEQ for review as projects are scheduled.

BMPs are installed for all construction projects as required.

Construction projects taking place during the 2014-15 permit year involved demolition and utility upgrades; they did not require post-construction BMPs.

5.2 – Maintain an inventory for all permanent SWM BMPs on base (post construction BMPs at JBM-HH include aboveground and underground detention facilities and water quality structures such as sand filters and Baysavers). Include fields for all data listed under b(4) of MCM 5.

Update continuously with new project information as it becomes available.

Inventory and tracking system updated with new information as it becomes available.

Inventory maintained in Microsoft Excel. Existing BMPs accounted for; no new SWM BMPs to add during 2014-15 permit year.

5.3 – To ensure these devices perform adequately and to track maintenance actions, develop a maintenance schedule that meets designer’s/manufacturer’s recommendations. Document all maintenance activities. Record maintenance actions in the tracking system for BMP 5.2.

Develop and finalize maintenance and inspection schedule with DPW.

Maintenance schedule developed and maintenance performed as recommended.

Maintenance schedule and tracking system was developed and finalized by DPW.

Minimum Control Measure 6: Pollution Prevention/Good Housekeeping for Municipal Operations

6.1 – Provide training. Evaluate current training program for adequacy in addressing stormwater pollution prevention and spill response.

Current training will be evaluated by end of PY1 and updated by middle of PY2, if necessary

Training updated if needed. All staff trained with annual refreshers provided. New staff trained within 6 months.

The 2011 computer-based stormwater pollution prevention and SPCC training program was evaluated in 2013. The evaluation indicated that the program did not include sufficient training on good housekeeping/pollution prevention practices during road, street, and parking lot maintenance. A training supplement was developed and distributed to all industrial operations shops to meet 2014 and 2015 employee training requirements.

6.2 – Conduct inspection and cleaning of roof gutters, street gutters, and storm drainage inlets as needed.

Cleanups as needed. Records of inspections and cleaning activities (frequency, amount of debris removed, manhours, etc.)

Storm drain inlets and structures that need cleaning and maintenance have been identified. EMD will continue to work with DPW to ensure maintenance is performed regularly.

6.3 – Update and implement SWPPP for facilities with municipal shop operations.

Complete updates by end of PY1. Fully implement within 6 months of completion. Conduct annual site compliance evaluations.

SWPPP updated and implemented. Annual compliance evaluations completed – no significant findings.

Annual compliance evaluation and SWPPP update completed June 2015.

JBM-HH MS4 2015 Annual Report - Attachment 3

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